The definition of a HMDA refinance is "any dwelling-secured loan that replaces and satisfies another dwelling-secured loan to the same borrower." I would like to know how banking institutions determine if the borrowers on the new dwelling-secured loan are the same as the borrowers on the old dwelling secured loan. Do you require the customer produce a copy of the note they wish to pay off? Do you have a field in your application to record this information? Thank you for your time.

Your question is worded so I'm under the impression you are not in the banking business.

The customer indicates on an application what kind of loan they are applying for. If they say refinance the bank will find out soon enough through the loan process if the person applying is the owner of the home.

Don,

I actually am in the banking business, but my question was regarding borrowers rather than owners. Any advise you might have would be greatly appreciated.